NUA & RMD timeline question

A client left their employer a few years ago, and the first distribution from her plan was a check she received for her 2022 RMD in January of 2023. My question is regarding the year that the LSD must be completed. Is it in 2022 since that is the year of her RMD, OR is it from the date the 2022 distribution was received in January of 2023? Just trying to determine if the trigger light is on or off.
Thank you!!!



They can still do the qualified LSD this year as long as there were no distributions after retiring prior to 2023. In fact, had the LSD been done prior to 4/2/23, the value of both the cost basis and the NUA probably would have satisfied both RMDs. But since the 2022 RMD check already issued was from other assets, the LSD can now only satisfy the 2023 RMD.



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